Legal Notices CLIENT RELATIONSHIP SUMMARY AT ONE CAPITAL MANAGEMENT, LLC WE RESPECT YOUR PRIVACY One Capital Management, LLC has adopted this policy with recognition that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We also know that you expect us to service you in an accurate and efficient manner. To do so, we must collect and maintain certain personal information about you. We want you to know what information we collect and how we use and safeguard that information.

What Information We Collect
We collect certain nonpublic personal identifying information about you (such as your name, address, social security number, etc.) from information that you provide on applications or other forms as well as communications (electronic, telephone, written or in person) with you or your authorized representatives (such as your attorney, accountant, etc.). We also collect information about your brokerage accounts and transactions (such as purchases, sales, account balances, inquiries, etc.).

What Information We Disclose
We do not disclose the nonpublic personal information we collect about our customers to anyone except: (i) in furtherance of our business relationship with them and then only to those persons necessary to effect the transactions and provide the services that they authorize (such as broker- dealers, custodians, independent managers etc.); (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law. We are permitted by law to disclose the nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or share the information for any other purpose. If you decide at some point to either terminate our services or become an inactive customer, we will continue to adhere to our privacy policy, as may be amended from time to time.

Security of Your Information
We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information.

Changes to Our Privacy Policy
Our policy about obtaining and disclosing information may change from time to time. We will provide you notice of any material change to this policy before we implement the change.

Questions:
If you have questions about this privacy policy, or if you wish to amend or rescind your written instructions below at any time, please contact Steven Cowley, Chief Compliance Officer at 805.409.8150.


DISASTER PREPAREDNESS & BUSINESS CONTINUITY PLAN OCM has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan. Responsibility

The Chief Compliance Officer (CCO) is responsible for creating and maintaining OCM's immediate and long-term contingency planning and recovery procedures that are appropriate to the scale and scope of OCM's business.
Notification of Proper Authorities

After an emergency has been declared, the CCO, or designee, will notify the proper regulatory authorities of the nature of the emergency, and the temporary location of the firm. Additionally, the same party will notify the local public utilities, the telephone company, the post office and any other vendor as deemed necessary.  
Telephone Service

In the event am emergency has been declared, our phone system will still be fully functioning. You can reach us at our regular phone number:   805-409-8150
  Temporary Operation Location/Recovery Site

If the primary office is inaccessible, OCM will relocate temporarily to a remote office outside of the affected emergency area.
  Client data is easily accessible at any remote location with Internet access as client data, including e-mail correspondence and pertinent books and records are backed up every 15 minutes to an archive disk on premises. Additionally, a full backup is made every 24 hours to our service provider, Infrascale, to allow for retrieval of client records when the primary office location is not accessible.  
   Client Contact

If a disaster occurs, every effort will be made by OCM to contact all clients. This will either be done by phone calls, emails, general mailing, and/or posting a message on OCM website. A list of all clients is maintained in OCM's account management system and can also be received by contacting the relevant account custodian.  
  Updates and Annual Review

OCM will update this plan whenever there is a material change to OCM's operations, structure, business or location or to those of our custodian (or any other critical service providers). In addition, OCM will test and update the plan, at least annually, to ensure the plan remains consistent with OCM's policy and overall business operations.
A full version of the Disaster Recovery Plan is available upon request. Custodian Contacts

If, after a significant business disruption, you cannot contact us directly as you usually do please call directly to your custodian as follows:
For Charles Schwab Accounts
www.schwab.com
1-800-435-4000

For TD Ameritrade Accounts
www.tdainstitional.com
1-800-669-3900

For Fidelity Accounts
www.fidelity.com
1-800-343-3548

For NBIN Accounts
www.nbcn.com
1-416-869-6695

For Pershing Accounts
www.pershing.com
Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm's books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.